Читать книгу International Taxation - Adnan Islam - Страница 84

In most cases, dividend income received from domestic corporations is U.S. source income. Dividend income from foreign corporations is usually foreign-source income. Exceptions to both of these rules are discussed in the following material.

A substitute dividend payment made to the transferor of a security in a securities lending transaction or a sale-repurchase transaction is sourced in the same manner as a distribution on the transferred security.